The National Association of Mortgage Brokers and Advisers (NAMBA) has circulated a survey about CP146 to its members. AIFA has given its members an opportunity to comment on the paper as well.
Both NAMBA and AIFA have highlighted for their members what they regard as the key areas of CP146 which affect mortgage intermediaries. These include:
• what rules should govern those mortgage intermediaries who are independent;
• how and when the status of the adviser should be disclosed;
• how suitability can be assessed;
• the regulations for 'non-advised filtering questions' (the mortgage equivalent of decision trees);
• the regulations for advised sales;
• product and commission disclosure; and
• training and competence requirements.
